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Written Descriptions Patent Invalidity Appeals

A&O Shearman

Federal Circuit Clarifies Requirements For A Prior Art Reference’s Entitlement To The Filing Date Of A Provisional Application To...

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On March 24, 2025, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) issued an opinion vacating and remanding a decision of the U.S. Patent Trial and Appeal Board (the “Board”) that a published patent application...more

McDermott Will & Emery

Complex or Not Written Description Is Evaluated Against Claims

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The US Court of Appeals for the Federal Circuit reversed a district court’s ruling of invalidity for lack of written description, finding that the district court erred in its analysis of written description because patents...more

Alston & Bird

Patent Case Summaries | Week Ending January 10, 2025

Alston & Bird on

Novartis Pharmaceuticals Corp. v. Torrent Pharma Inc., et al., Nos. 2023-2218, -2220, -2221 (Fed. Cir. (D. Del.) Jan. 10, 2025). Opinion by Lourie, joined by Prost and Reyna. The FDA approved a New Drug Application from...more

McDermott Will & Emery

Later-Filed, Earlier-Expiring Patent Not an ODP Reference

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Addressing invalidity due to obvious-type double patenting (ODP) based on later-filed-related patents, the US Court of Appeals for the Federal Circuit reversed a district court’s application of In re Cellect (Fed. Cir. 2023)...more

McDermott Will & Emery

Holy Pulmonary Hypertension, Batman: Method of Treatment Not Constrained by Safety and Efficacy

The US Court of Appeals for the Federal Circuit affirmed a district court’s holding that the asserted method of treatment patent was valid and infringed because safety and efficacy are not patent concerns. The Federal Circuit...more

Fitch, Even, Tabin & Flannery LLP

Federal Circuit Finds No Alternative Holding in District Court Opinion and Rejects Appeal

On April 20, in Sebela Ireland v. Prinston Pharmaceutical, the Federal Circuit held that Sebela’s appeal challenged only contingent patent invalidity findings and dismissed the appeal for lack of constitutional standing. In...more

Akin Gump Strauss Hauer & Feld LLP

Federal Circuit Snubs Extrinsic Evidence in Reversing Ruling on 12(b)(6) Motion Arguing Invalidity Under § 101

In CardioNet, LLC, et al. v. InfoBionic, Inc., the Federal Circuit reversed a district court’s ruling that affirmed a defendant’s 12(b)(6) motion that the asserted claims are invalid under 35 U.S.C. § 101, based on step one...more

McDermott Will & Emery

Broad Genus of HCV Compounds Wasn’t Enabled or Described

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In a case relating to compounds for the treatment of the Hepatitis C virus (HCV), the US Court of Appeals for the Federal Circuit upheld a district court’s grant of judgment as a matter of law (JMOL) for lack of enablement...more

Knobbe Martens

Federal Circuit Review - October 2019

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The PTAB Cannot Approve or Deny Certificates of Correction - In Honeywell International, Inc. v. Arkema Inc., Arkema France, Appeal Nos. 2018-1151, -1153, the Patent Trial and Appeal Board (“Board”) does not have the...more

Knobbe Martens

Federal Circuit Review - August 2019

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Mere Potential for Future Appeal Does Not Prevent Triggering Estoppel of Inter Partes Reexamination When Party Fails to Seek Relief in the First Instance - In Virnetx Inc. v. Apple Inc., Appeal Nos. 2017-1591, -1592,...more

McDermott Will & Emery

Equivalent Disclosure Used to Satisfy Written Description Requirement

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Invoking a newly minted equivalent disclosure doctrine, a panel of the US Court of Appeals for the Federal Circuit found that the written description requirement of § 112 was satisfied in the interest of arriving at a...more

McDermott Will & Emery

When Is Batting “Lofty”? Look to the Specification

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In an opinion addressing the definiteness of a term of degree, the US Court of Appeals for the Federal Circuit affirmed a final determination of the US International Trade Commission (ITC), concluding that an asserted claim...more

Knobbe Martens

Terms of Degree with Objective Boundaries Are Not Indefinite

Knobbe Martens on

GUANGDONG ALISON HI-TECH CO. V. ITC - Before Wallach, Hughes, and Stoll. Appeal from United States International Trade Commission. Summary: A term of degree is not indefinite so long as the written description provides...more

McDermott Will & Emery

Mismatch Between Claims and Specification Leads to Invalidity

The US Court of Appeals for the Federal Circuit affirmed a Patent Trial and Appeal Board (PTAB) invalidity decision in an interference proceeding, finding that the written description of the patent at issue did not describe...more

Knobbe Martens

Federal Circuit Review - July 2019

Knobbe Martens on

Broad Claim Language and Unpredictability in the Art Lead to Non-Enablement - In Enzo Life Sciences, Inc. v.  Roche Molecular Systems, Inc., Appeal Nos. 2017-2498, -2499, -2545, -2546, broad patent claims were invalid as...more

McDermott Will & Emery

Flow Valve Shut Off from Reissue

The US Court of Appeals for the Federal Circuit invalidated reissue patent claims for impermissible broadening, finding that the newly claimed subject matter did not comply with the requirement of 35 USC § 251(a) that reissue...more

McDermott Will & Emery

Just Because It’s Written Doesn’t Mean It’s Descriptive

Addressing the validity of patents involved in a Hatch-Waxman litigation, the US Court of Appeals for the Federal Circuit held that claims were invalid for lack of an adequate written description because the specification...more

McDermott Will & Emery

Merely Contemplating Alternative Embodiment May Satisfy Written Description

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Addressing a decision granting summary judgment of invalidity due to lack of sufficient written description and noninfringement, the US Court of Appeals for the Federal Circuit explained that a patent holder’s contentions...more

Knobbe Martens

Centrak, INC. v. Sonitor Technologies, INC.

Knobbe Martens on

Federal Circuit Summary - Before Reyna, Taranto, and Chen. Appeal from the United States District Court for the District of Delaware. Summary: Where the complexity and predictability of a claimed embodiment were...more

Schwabe, Williamson & Wyatt PC

Fresh From the Bench: Latest Federal Circuit Court Cases

D Three Enterprises, LLC v. SunModo Corporation, Appeal Nos. 2017-1909, -1910 (Fed. Cir. May 21, 2018) - The Court affirmed a grant of summary judgment of invalidity in favor of patent infringement defendants, based on a...more

Knobbe Martens

D Three Enterprises, LLC v. Sunmodo Corporation

Knobbe Martens on

Federal Circuit Summaries - Before Reyna, Clevenger, and Wallach. Appeal from the United States District Court for the District of Colorado - Summary: Even in a simple mechanical case, a narrow disclosure in the...more

Schwabe, Williamson & Wyatt PC

2017 Supreme Court and Precedential Patent Cases From the Federal Circuit, With Some Significant Cases from 2016

Arbitration - Waymo v. Uber Technologies, 870 F.3d 1342 (Fed. Cir. 2017) - Waymo sued Uber and others for trade secret misappropriation and patent infringement. Uber contends that Waymo should be compelled to...more

McDermott Will & Emery

Remand Where PTAB Decision Does Not Explain Reasoning, Account for All Evidence

In reviewing a decision from the Patent Trial and Appeal Board (PTAB) deciding three interferences involving competing claims directed to testing methods for fetal aneuploidies, the US Court of Appeals for the Federal Circuit...more

Schwabe, Williamson & Wyatt PC

Fresh From the Bench: Precedential Patent Cases From the Federal Circuit:

The big news this week (and it is particularly big news in Tyler and Marshall, Texas) is that the ?Supreme Court rules that a defendant “resides” for purposes of the patent venue statute only ?where the defendant actually ?is...more

Mintz - Intellectual Property Viewpoints

You Can Not Claim What you Don’t Possess – Federal Circuit Holds Fiber Optic Claims Invalid under Section 112

On May 10, 2017 and following a Patent Trial and Appeal Board (PTAB) reexamination decision upholding certain claims, the United States Court of Appeals for the Federal Circuit ruled in Cisco Systems, Inc. v. Cirrex Systems,...more

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